Version 2.1, dubbed Éclair, accounts for 41.7% of devices and that's down from 55% according to Google's July figures. The latest numbers were tallied over a two-week period ending Sept. 1. Froyo, had just 3% of the share in July, but it was hardly on the market at that point.

Despite the fact that more than 70% of Android devices run Version 2.1 or 2.2, there remains considerable fragmentation in the Android market, which can be a big hassle for developers trying to figure out where to put their resources. Apple has no such issues since only its devices run iOS, now on Version 4.

Google has taken steps to simplify Android apps development, including through the recent release of its App Inventor for Android, which is designed to enable anyone to build Android smartphone apps.

There's also some confusion in the market about whether Android is really designed to run on tablets, with Google and Verizon said to be working in this area.

Google is expected to set stricter guidelines for Android device makers in Android 3.0, known as Gingerbread. Reports have stated that Google will require a 1GHz processor, 512MB of RAM and displays of at least 3.5 inches.